Court Case Challenges Life Sentences for Juveniles in Florida
Last week, the 11th Circuit Court of Appeals heard oral arguments over the parole practices for juvenile offenders in Florida who were sentenced to life in prison with the possibility of parole. However, they claim that because of Florida's strict rules on parole, their constitutional rights are being violated. Practically speaking, they argue, they can't get parole, even if it's theoretically possible.
The Details and Supreme Court Precedent
The case, called Howard v. Coonrod, originated from a 2021 class action lawsuit filed against the Florida Commission on Offender Review. The plaintiffs are a group of inmates convicted of murder as juveniles and who were sentenced to life with the possibility of parole. They argue that Florida's parole system violates their constitutional rights.
These plaintiffs claim that the system fails to provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by an important ruling from the U.S. Supreme Court in 2012, in the case of Miller v. Alabama.
What happened in Miller? The central legal issue before SCOTUS was whether mandatory life imprisonment without the possibility of parole for juveniles are constitutional.
The majority opinion, authored by Justice Kagan and joined by Justices Kennedy, Ginsburg, Breyer, and Sotomayor, answered “no.” Specifically, these justices found that such sentences violate the Eighth Amendment's prohibition on cruel and unusual punishments because they do not allow for individualized sentencing considerations that take into account the unique characteristics of youth.
The majority applied precedents from previous cases, such as Roper v. Simmons and Graham v. Florida, which established that certain harsh penalties cannot be imposed on juveniles. The decision extended the reasoning of these cases to mandatory life without parole for juvenile homicide offenders.
The Court examined whether the punishment is proportionate to both the offender and the offense. It emphasized the concept of proportionality as central to the Eighth Amendment and noted that punishment should be graduated and proportioned to the offender's culpability and the nature of the offense.
Mandatory Sentences
The Supreme Court also addressed the specific issue of mandatory sentencing schemes that impose life imprisonment without the possibility of parole on juvenile offenders. The majority concluded that such mandatory sentencing schemes are unconstitutional when applied to juveniles because they fail to consider the unique characteristics and mitigating factors associated with youth.
The Court's decision emphasized that juveniles are constitutionally different from adults for sentencing purposes due to their diminished culpability and greater capacity for change. SCOTUS held that imposing a mandatory life-without-parole sentence on a juvenile offender violates the Eighth Amendment's prohibition on cruel and unusual punishments because it disregards the offender's age, background, and the circumstances of the offense.
What to Expect in Howard v. Coonrod
Although the judges of the 11th Circuit have not set a date for reaching a decision in the current case, they did give some hints to what’s on their mind over oral arguments. The judges' questioning focused on the effectiveness and fairness of Florida's parole system, particularly regarding whether it provides a meaningful opportunity for release based on maturity and rehabilitation.
Jeffrey DeSousa, an attorney for the State of Florida, pointed out that the parole commission does actually consider the defendant’s age and youth in its parole hearings and the commissioners hold interviews after the initial parole hearing. “Those subsequent interviews are meaningful,” he said. “I think that shows our process is working.”
Judges Newsom and Pryor challenged Levick's claim that the parole system effectively results in life sentences without the possibility of release by pointing out that some class members have been released. Marsha Levick, the attorney representing the juvenile offenders, acknowledged that 22 of her clients had been released in the past 12 years.
We might not get an answer this calendar year. Until then, hundreds of Floridians that were sentenced as juveniles wait for a decision that will impact the future of the Florida’s youth.
Related Resources:
- Juveniles and the Death Penalty (FindLaw's Learn About the Law)
- The Juvenile Justice System: Introduction (FindLaw's Learn About the Law)
- How Do Juvenile Proceedings Differ From Adult Criminal Proceedings? (FindLaw's Learn About the Law)
